Web(2) Adjustments for redemptions, liquidations, reorganizations, divisives, etc. In the case of any transaction involving the application of subchapter C to any S corporation, proper adjustment to any accumulated earnings and profits of the corporation shall be made. WebSec. 1377 (a) (2) applies to situations in which a shareholder terminates his or her complete interest in the S corporation. This does not apply when a …
26 U.S.C. § 1377 (2024) - Definitions and special rule :: 2024 US …
WebI.R.C. § 1371 (c) (2) Adjustments For Redemptions, Liquidations, Reorganizations, Divisives, Etc. — In the case of any transaction involving the application of subchapter C to any S corporation, proper adjustment to any accumulated earnings and profits of … WebA prior section 1377, added Pub. L. 85–866, title I, §64(a), Sept. 2, 1958, ... In no event shall the 120-day period referred to in section 1377(b)(1)(B) of the Internal Revenue Code of 1986 (as added by such section 1307) expire before the end of the 120-day period beginning on the date of the enactment of this Act [Aug. 5, 1997]." ... ir35 working for foreign company
eCFR :: 26 CFR 1.1367-1 -- Adjustments to basis of shareholder
WebFor purposes of the terminating election under section 1377 (a) (2) and paragraph (b) of this section, the term affected shareholders means the shareholder whose interest is terminated and all shareholders to whom such shareholder … Web26 U.S. Code § 1368 - Distributions. A distribution of property made by an S corporation with respect to its stock to which (but for this subsection) section 301 (c) would apply shall be treated in the manner provided in subsection (b) or (c), whichever applies. The distribution shall not be included in gross income to the extent that it does ... WebL. 109–135 substituted “a depository institution holding company (as defined in section 3(w)(1) of the Federal Deposit Insurance Act (12 U.S.C. 1813(w)(1))” for “a bank holding company (within the meaning of section 2(a) of the Bank Holding Company Act of 1956 (12 U.S.C. 1841(a))), or a financial holding company (within the meaning of ... ir35 what it means